Legal Opinion
Charles Y. Choi Jin Yi Choi v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided August 10, 2004No. 02-74480PublishedCited by 7 opinions
1Opinion of the Court
SCHROEDER, Chief Judge:
Taxpayers, Charles Y. Choi and his wife Jin Yi Choi, appeal the Tax Court’s determination that they underreported the income from their Arizona grocery store on their 1991 and 1992 federal tax returns and the imposition of a civil fraud penalty under 26 U.S.C. § 6663. It is undisputed that the Chois did not maintain adequate records for the store and that the Commissioner therefore was entitled to use an indirect method of reconstructing income to determine the amount of any deficiency. 26 U.S.C. § 446(b). The Commissioner used the “bank deposits plus cash expenditures”…
2Cases cited6 opinions
- Nor-Cal Adjusters, AKA Nor-Cal Insurance Adjusters, Formerly Hobson Adjusters, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
- Lillian Bernstein, of the Estate of Kalman Bernstein, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- United States v. Ronnie Joseph BrickeyCourt of Appeals for the Ninth Circuit · 2002
- Raymond Percifield v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- Kirsch v. United StatesCourt of Appeals for the Eighth Circuit · 1949
1 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Nick Kikalos and Helen Kikalos v. United StatesCourt of Appeals for the Seventh Circuit · 2005
- Kovacevich v. CommissionerCourt of Appeals for the Ninth Circuit · 2006
- MacGregor v. CommissionerCourt of Appeals for the Ninth Circuit · 2012
- Francis Hayes v. CirCourt of Appeals for the Ninth Circuit · 2021
- Kikalos, Nick v. United StatesCourt of Appeals for the Seventh Circuit · 2005
2 more not listed; retrieve them via the Exa API.